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CA Final · Direct Tax Laws & International Taxation · Assessment Procedure

Ruchika Textiles Pvt Ltd is under faceless assessment. The assessment unit proposes a variation prejudicial to the company's interest, and a show cause notice has been served through the National Faceless Assessment Centre (NFAC). The company's director wants to explain the matter orally. Under Rule 176 of the Income-tax Rules, 2026, what is the correct position?

Where a variation is proposed, the assessee may request a personal hearing. The hearing is allowed through the National Faceless Assessment Centre and is held exclusively by video conferencing or video telephony, to the extent technologically feasible. Physical appearance is not permitted in faceless proceedings.

  1. ANo oral submission is possible because personal appearance is barred in every circumstance
  2. BThe company may request a personal hearing, which is conducted exclusively through video conferencing or video telephony, to the extent technologically feasibleCorrect
  3. CThe company may insist on a physical hearing at the office of the Assessing Officer having jurisdiction
  4. DThe hearing is conducted directly between the assessee and the assessment unit without routing through the NFAC

Explanation

Rule 176(3)(f) bars personal appearance generally, but (3)(g) lets the assessee request a personal hearing where a variation is proposed. Under (3)(h) the hearing is allowed through the NFAC and is conducted exclusively by video conferencing or video telephony, to the extent technologically feasible. A physical hearing, as in the second-best distractor, is therefore wrong.

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